### Re: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1). Chuantung Lin to: Paul Campanella 11/13/2012 02:19 PM Cc: Tracy Williamson, Myrta Christian, David Brooks, John Schaeffer History: This message has been replied to and forwarded.

Hi Paul,

The HPV3 Test Rule requires A1, A2, A3, A4, and A5 testing (P/C endpoints) for [52556-42-0} (assumes a pure substance (99%) is available) . If the sponsor of this chemical insists that the pure substance is not possible to obtain in commerce, then there is no points to perform these P/C endpoints testing. The reasons are the following:
1) The test substance/sample is always in a 40% aqueous solution not the pure substance at all ;
2) The test of A1 (M.P.), A2 (B.P.), and A3 (V.P.) will be all on the aqueous sample, the results will be not relevant to the endpoints HPV3 Test Rule is aiming for to fulfill the P/C data gap. All the test result on the aqueous sample solution (i.e, using AkzoNobel AHPS product) will be for the solvent (in this case, is water) and not for COPS-1.
3) Since the sample solution contains ~40% of COPS-1 (in ~52-57 % of water), the minimum water solubility of COPS-1 should be >40% and therefore, don't require additional testing for this endpoint at all. We could use 40% for the water solubility endpoint.
4) As the sponsor indicated that the Log Kow value will be expected to much less than 0 (i.e., very soluble). The EPI's estimation shows around "-5.0". It will not be necessary to test this endpoint.
Base on these facts and the sponsor's reasoning of no 99% pure of substance is available for this test substance, ICB recommends that these five P/C endpoints should be dropped from testing.
Whether using the 40% solution as the test sample for biodegradation issue and other toxic endpoints testing are EAB and RAD's calls.
Let me know if you have further question on this matter. Thanks!

Daniel

_

____________________________________________________ _ Dr. Daniel Chuantung Lin Industrial Chemistry Branch Office of Chemicals Safety and Pollution Prevention US EPA 1200 Pennsylvania Ave., NW (7406M) Washington, DC 20460

[Deliveries to: 1201 Constitution Ave., NW, EPA East, Room#:5133E, Washington, DC 20460]
202-564-8584 (direct) 202-564-8740 (branch) 202-564-8679 (fax)Paul Campanella 11/12/2012 08:25:47 PM Daniel, Tucker Helmes believes this is what you...

From: Paul Campanella/DC/USEPA/US To: Chuantung Lin/DC/USEPA/US@EPA Date: 11/12/2012 08:25 PM Subject: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Daniel, Tucker Helmes believes this is what you need to make the analysis. If this is not sufficient please let me know. Thanks.

----- Forwarded by Paul Campanella/DC/USEPA/US on 11/12/2012 08:21 PM -----

From: Tucker Helmes <HelmesT@socma.com> To: Paul Campanella/DC/USEPA/US@EPA Cc: David Brooks/DC/USEPA/US@EPA, John Schaeffer/DC/USEPA/US@EPA Date: 11/12/2012 09:04 AM Subject: RE: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).



### Paul,

Attached is an amended AHPS analysis summary sheet providing the CAS number for AHPS (same as for COPS

‐ 1). This should give you what you need.

Tucker

Dr. C. T. Helmes Senior Director Society of Chemical Manufacturers and Affiliates 1850 M Street, NW Suite 700 Washington, DC 20036 Tel 202-721-4154 / Fax 202-296-8120 helmest@socma.com

From: Campanella.Paul@epamail.epa.gov [mailto:Campanella.Paul@epamail.epa.gov] Sent: Friday, November 09, 2012 11:26 A M To: Tucker Helmes Cc: Brooks.David@epamail.epa.gov ; Schaeffer.John@epamail.epa.gov Subject: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Tucker , can you provide the information that Dr. Lin is asking for. Thanks.

Paul J. Campanella, Ph.D.Chemical Information and Testing Branch Chemical Control Division U.S. Environmental Protection Agency Washington, D.C. 202-564-8091 ----- Forwarded by Paul Campanella/DC/USEPA/US on 11/09/2012 11:25 A M -----

From: Chuantung Lin/DC/USEPA/US To: Paul Campanella/DC/USEPA/US@EPA Cc: David Brooks/DC/USEPA/US@EPA, Tracy Williamson/DC/USEPA/US@EPA, Myrta Christian/DC/USEPA/US@EPA Date: 11/09/2012 11:15 A M Subject: Re: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Hi Paul,

When I tried to compare the two products (COPS-1; CASRN 52556-42-0) and AlzoNobel AHPS (no CASRN & Chemical identity), I found it is impossible to do. The sponsor only stated that " A kzo’s produc t is called AHPS but is identical to COPS-1". I need the full Chem ID (CASRN & CA Index Name) for A kzoNobel AHPS in order to decide whether these two chemicals are indeed the same chemical. Could you ask the sponsor to provide such information?

Daniel

_ ________________________________________ Dr. Daniel Chuantung Lin Industrial Chemistry Branch Office of Chemicals Safety and Pollution Prevention US EPA 1200 Pennsylvania Ave., NW (7406M) Washington, DC 20460

[Deliveries to: 1201 Constitution Ave., NW, EPA East, Room#:5133E, Washington, DC 20460]

202-564-8584 (direct) 202-564-8740 (branch) 202-564-8679 (fax)

-----Paul Campanella/DC/USEPA/US wrote: ----- To: Chuantung Lin/DC/USEPA/US, David Brooks/DC/USEPA/US From: Paul Campanella/DC/USEPA/US Date: 11/08/2012 04:07PM Subject: Fw: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Daniel and David. Here is an issue we have run into before. The purity of the test substance. This is particularly important just now because the consortium has ordered the animals and wants to start testing the week of Nov 27-30. If we can give them a quick read on this they will go ahead. If not they will have to delay the start up and go through all the paperwork of asking for an extension of the date to submit test data etc. I hope we can provide them a answer in a reasonable time. Thanks for your help.Paul J. Campanella, Ph.D. Chemical Information and Testing Branch Chemical Control Division U.S. Environmental Protection Agency Washington, D.C. 202-564-8091 ----- Forwarded by Paul Campanella/DC/USEPA/US on 11/08/2012 04:04 PM -----

From: Tucker Helmes < HelmesT @ socma

. com > To: Paul Campanella/DC/USEPA/US@EPA Date: 11/08/2012 03:59 PM Subject: HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1).

Paul,

Following up on our phone call just now re. HPV3 EPA Review of Testing Plans for CASRN 52556-42-0 (COPS-1) , I attach some pertinent information including the COA of the COPS-1 test material which will be supplied by Bimax. The second attachment (CONFIDENTIAL) is conformation of the sample purity from Bimax.

For comparison, the last four attachments provide analysis of AHPS by AkzoNobel, another member of the consortium. A kzo’s product is called AHPS but is identical to COPS-1. The AkzoNobel analysis is backed up by an nmr and analytical determination methods. Y ou can see that COPS-1 and AHPS are virtually identical in composition and purity. Both are representative of the typical commercial product of the subject test substance produced by consortium members.

A s COPS-1 is a salt, achieving 99% purity is not feasible. It would require 

### commercial recrystallization units which are costly to purchase and the energy cost of running it on a commercial scale cost prohibitive for industrial uses. It would also require specialized dry handling capabilities at the polymerization step. This makes no sense when the sole use of the COPS-I is to further polymerization reactions into aqueous polymers. In this case, the manufacture of dry monomer does not seem relevant to the exposure component of risk assessment.

Please let me know if when discussing this with your colleagues you have further questions. Naturally we’d like to get this program moving to comply with the timeline and avoid the lengthy process of requesting a test rule modification through the docket office.

Thanks very much for your help in this matter. Looking forward to hearing back from you.

Tucker

Dr. C. T. Helmes Senior Director Society of Chemical Manufacturers and Affiliates 1850 M Street, NW Suite 700Washington, DC 20036 Tel 202-721-4154 / Fax 202-296-8120 helmest @ socma

. com

(See attached file: COA bimax 081312. p df )(

See attached file: COPS-1 p urit y

110812.docx )(

See attached file: A kzoNobel AHPS analysis. p df )(

See attached file: A kzoNobel COPS GC Chromatogram. p df )(

See attached file: A kzoNobel Memo on Analytical Methods to Analyze AHP S Monomer 120106.doc )(

See attached file: A kzoNobel QCTM 711 Determination of residual Allyl Glycidyl Ether ( A G E ) and 3- A llylox y

-12-Propanediol (GAE ) in Monomer AHPS by Gas Chromatography.doc ) 

### (See attached file: COA bimax 081312. p df )( See attached file: COPS-1 p urity 110812.docx )( See attached file: A kzoNobel AHPS analysis. p df )( See attached file: A kzoNobel COPS G C Chromatogram. p df )( See attached file: A kzoNobel Memo on Analytical Methods to Analyze A HPS Monome r 120106.doc )( See attached file: A kzoNobel QCTM 711 D etermination of residual Allyl Glycidyl Ether ( A G E ) and 3- A llyloxy-12- P ropanediol (GAE ) in Monomer AHPS

by Gas Chromatography.doc )